State v. Bellamy, 2014 Ohio 5187

Bellamy convicted by jury of violating a protection order and of menacing by stalking; Murray ended relationship and obtained a protection order in March 2013; Bellamy made threatening phone calls to Murray’s workplace and to coworkers; calls were often from an unknown number and voice matched Bellamy; investigators and witnesses identified Bellamy as caller; discovery violation led to exclusion of texts and emails at trial; judgment of 30 months' imprisonment affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of texts and emails from discovery	Bellamy argues texts/emails show friendly relation, could negate stalking	Exclusion was too harsh; should have been allowed or continued	Exclusion not abuse of discretion; harmless error

State v. Grindstaff, 2014-Ohio-2581 (12th Dist. Clermont No. CA2013-09-074) (evidentiary rulings require abuse of discretion standard)
State v. Darrah, 2007-Ohio-7080 (12th Dist. Warren No. CA2006-09-109) (requirements for error preservation and proffered evidence under Evid.R. 103(A))
State v. Gilmore, 28 Ohio St.3d 190 (1986) (necessity of showing substantial right and proffer for evidentiary errors)
State v. Wilson, 2013-Ohio-3877 (12th Dist. Butler No. CA2012-12-254) (sanctions for discovery violations balance prejudice and defense right)
City of Lakewood v. Papadelis, 32 Ohio St.3d 1 (1987) (least severe discovery sanction appropriate under circumstances)